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Generate professional replies to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
Step 1 – Issue Identification & Review
The AI analyses your query, notice, order, or uploaded documents and identifies the key issues involved.
• Review the issues identified by the AI
• Add, edit, remove, or refine issues as required
Step 2 – Draft Generation
Once you approve the issues, the AI performs issue-wise legal research and prepares a structured draft response.
• Relevant statutory provisions
• Judicial precedents and Supreme Court, High Court and other citations
• Issue-wise legal analysis
• Practical arguments and supporting content
• Professionally structured draft ready for further review. 
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Issues: Whether, at the prima facie stage, the impugned FIR disclosed a second FIR in respect of the same transaction so as to justify interim protection against coercive action.
Analysis: The petitions were examined on a limited interim basis to see whether the later FIR substantially covered the same loan accounts and borrower group already mentioned in the earlier FIR. On that prima facie comparison, the later FIR appeared to overlap with the earlier FIR in respect of the same set of transactions. The governing principle applied was that while investigation into offences arising from the same transaction may continue, a second FIR for the very same transaction is impermissible. In that context, protection was considered necessary to avoid jeopardising personal liberty during the pendency of the petitions.
Conclusion: The challenge to the second FIR was found to warrant consideration at the interim stage, and interim protection against coercive action was granted while permitting the investigation to continue.
Ratio Decidendi: A second FIR in respect of the same transaction or occurrence is not maintainable, though further investigation in the same transaction may proceed.